A Philadelphia woman pleaded guilty to a criminal information unsealed today charging her with causing false statements to the Federal Election Commission (FEC) in connection with a 2012 congressional primary election.

According to the plea memorandum, Carolyn Cavaness, 34, engaged in a falsification scheme involving payments to a candidate for the Democratic Party’s nomination for Member of the U.S. House of Representatives. According to the plea memorandum, those payments came from the campaign committee of the candidate’s political opponent for the purpose of removing the candidate from the 2012 Democratic race for Pennsylvania’s First Congressional District. Cavaness was a member of the candidate’s campaign staff.

As set forth in the criminal information and the government’s plea memorandum, Cavaness admitted that in or about February 2012, her candidate withdrew from the primary election pursuant to an agreement with his opponent, who promised to pay the candidate $90,000 from his campaign funds to be used to repay the candidate’s campaign debts. Cavaness admitted that she was aware that under the applicable law, a contribution from one authorized campaign to another could not exceed $2,000 for the primary election, and that the FEC required campaigns to file periodic reports itemizing the campaign’s contributions and expenditures during the reporting period. However, in order to conceal the fact that his opponent’s campaign committee paid his campaign debts, according to the plea memorandum, the candidate instructed Cavaness to create a company whose sole purpose would be to receive the funds from his opponent’s political campaign and repay the candidate’s campaign debts. As described in the plea memorandum, Cavaness admitted that she did so, and that the payments were then routed through two political consultants, who created false invoices to generate a paper trail intended to justify the payments from the candidate’s opponent’s campaign committee.

According to the plea memorandum, Cavaness used the money from the opponent’s campaign committee to repay the candidate’s campaign debts and for personal expenses, but failed to disclose this information to the FEC. Instead, according to the plea memorandum, Cavaness knowingly and intentionally caused the candidate’s campaign committee to file false reports with the FEC which did not disclose or reference the funds received from his opponent’s campaign committee, did not mention the companies of the political consultants through which the payments were routed and falsely listed the same debts owed by the candidate’s campaign that had been disclosed on earlier reports, despite the fact that those debts had been repaid using funds paid to the candidate by his opponent’s campaign committee.